Policy on data subject/client’s rights (GDPR compliant)
Aim and scope of this policy
Cullens Driving School may process certain types of data for business operations purposes. Cullens Driving School is fully aware of its obligations under the General Data Protection Regulation (GDPR) to process data lawfully and to ensure that the rights of data subjects, as set out in GDPR, are observed correctly. This policy sets out the rights of the aforementioned individuals as data subjects and the processes which should be followed in the event that the data subject wishes to exercise any such right.
Data subject rights
Under GDPR, you have the following rights in relation to your data:
The right to be informed
You have the right to be told how Cullens Driving School processes your data and the reasons for the processing. In order to provide this information to you,Cullens Driving School has a privacy notice to explain what data we collect about you, how we collect and process it, what we process it for and the lawful basis which permits us to process it. You can obtain a copy of the privacy notice, at no cost, upon request to Cullens Driving School.
If Cullens Driving School intends to use data already collected from you for a different reason than that already communicated i.e. for marketing purposes, you will be informed of the new reason in advance and be given the decision to opt-out.
The right of access
You have the right to access your personal data which is held by Cullens Driving School More information on this is available in our Subject Access Request policy which is available from Cullens Driving School upon request.
The right for data to be corrected
One of the fundamental principles underpinning data protection is that the data Cullens Driving School processes about you will be accurate and up to date. You have the right to have your data corrected if it is inaccurate or incomplete.If you wish to have your data rectified, you should do so by getting in touch with us and informing us what data you would like rectified.
Cullens Driving School will respond to a data rectification request within one month. Where the data rectification request is complex, then we may extend the timescale for response from one month to three months. If this is the case, we will write to you within one month of receipt of the request explaining the reason for the extension.
If the response to your request is that Cullens Driving School will take no action, you will be informed of the reasons for this and of your right to complain to the ICO.
Where any data which has been rectified was disclosed to third parties in its un-rectified form, Cullens Driving School will inform the third party of the rectification where possible. Cullens Driving School will also inform you of the third parties to whom the data was disclosed
The right to have information deleted
You have the right to have your data deleted and removed from any of our systems where there is no compelling business reason for Cullens Driving School to continue to process it.
You have a right to have your data deleted in the following circumstances:
The right to restrict the processing of data
You have the right to restrict the processing of your data in certain circumstances. Restricting Cullens Driving School from processing your data means that we will continue to hold the data but will stop processing it.
Cullens Driving School will be required to restrict the processing of your personal data in the following circumstances:
If you wish to make a request for data restriction, then please contact us informing us what data you would like to be restricted.
Where data processing is restricted,Cullens Driving School will continue to hold the data but will not process it unless:
Where Cullens Driving School is to lift any restriction on processing, you will be informed in advance.
The right to data portability
You have the right to obtain the data that Cullens Driving School processes on you and use it for your own purposes. This means you have the right to receive the personal data that you have provided to Cullens Driving School in a structured machine-readable format and to transmit the data to a different data controller.
This right applies in the following circumstances:
If you wish to exercise this right, please contact Cullens Driving School
Where a request for data portability is received, Cullens Driving School will respond without undue delay, and within one month at the latest. Where the request is complex or Cullens Driving School receives a number of requests, Cullens Driving School may extend the timescale for response from one month to three months. If this is the case, Cullens Driving School will write to you within one month of receipt of the request explaining the reason for the extension.
If the response to your request is that Cullens Driving School will take no action, you will be informed of the reasons for this and of your right to complain to the ICO.
The right to portability is different from the right to access. Although both involve a right to access your personal data, the personal data to be accessed is not the same. The right to access your data under the right to portability includes only personal data as described above. Access to data under the right of access includes all personal data relating to you, including that which has not been provided to Cullens Driving School by you.
The right to object to the inclusion of data
You have a right to object to the processing of your data in certain circumstances. This means that you have the right to requireCullens Driving School to stop processing your data. In relation to your services with Cullens Driving School, you may object to processing where it is carried out:
If you wish to object, you should do so by contacting us.
Where you object to processing,Cullens Driving School will stop the processing activity objected to unless:
Cullens Driving School can demonstrate compelling legitimate reasons for the processing which are believed to be more important than your rights
or the processing is required in relation to legal claims made by, or against, Cullens Driving School
If the response to your request is that Cullens Driving School will take no action, you will be informed of the reasons.
Rights in relation to automated decision making
You have the right not to have decisions made about you solely on the basis of automated decision-making processes where there is no human intervention, where such decisions will have a significant effect on you. However,Cullens Driving School does not make any decisions based on such processes.
If you wish to exercise this right, you should speak to Cullens Driving School
However, we may carry out automated decision making with no human intervention in the following circumstances:
Aim and scope of this policy
Cullens Driving School may process certain types of data for business operations purposes. Cullens Driving School is fully aware of its obligations under the General Data Protection Regulation (GDPR) to process data lawfully and to ensure that the rights of data subjects, as set out in GDPR, are observed correctly. This policy sets out the rights of the aforementioned individuals as data subjects and the processes which should be followed in the event that the data subject wishes to exercise any such right.
Data subject rights
Under GDPR, you have the following rights in relation to your data:
- the right to be informed
- the right of access
- the right for any inaccuracies to be corrected
- the right to have information deleted
- the right to restrict the processing of the data
- the right to portability
- the right to object to the inclusion of any information
- the right to regulate any automated decision-making and profiling of personal data.
The right to be informed
You have the right to be told how Cullens Driving School processes your data and the reasons for the processing. In order to provide this information to you,Cullens Driving School has a privacy notice to explain what data we collect about you, how we collect and process it, what we process it for and the lawful basis which permits us to process it. You can obtain a copy of the privacy notice, at no cost, upon request to Cullens Driving School.
If Cullens Driving School intends to use data already collected from you for a different reason than that already communicated i.e. for marketing purposes, you will be informed of the new reason in advance and be given the decision to opt-out.
The right of access
You have the right to access your personal data which is held by Cullens Driving School More information on this is available in our Subject Access Request policy which is available from Cullens Driving School upon request.
The right for data to be corrected
One of the fundamental principles underpinning data protection is that the data Cullens Driving School processes about you will be accurate and up to date. You have the right to have your data corrected if it is inaccurate or incomplete.If you wish to have your data rectified, you should do so by getting in touch with us and informing us what data you would like rectified.
Cullens Driving School will respond to a data rectification request within one month. Where the data rectification request is complex, then we may extend the timescale for response from one month to three months. If this is the case, we will write to you within one month of receipt of the request explaining the reason for the extension.
If the response to your request is that Cullens Driving School will take no action, you will be informed of the reasons for this and of your right to complain to the ICO.
Where any data which has been rectified was disclosed to third parties in its un-rectified form, Cullens Driving School will inform the third party of the rectification where possible. Cullens Driving School will also inform you of the third parties to whom the data was disclosed
The right to have information deleted
You have the right to have your data deleted and removed from any of our systems where there is no compelling business reason for Cullens Driving School to continue to process it.
You have a right to have your data deleted in the following circumstances:
- where the personal data is no longer necessary in relation to the purpose for which Cullens Driving School originally collected or processed it.
- where you have withdrawn your consent to the continued processing of the data and there is no other lawful basis for Cullens Driving School to continue processing the data.
- where you object to the processing and Cullens Driving School has no overriding legitimate interest to continue the processing.
- the personal data has been unlawfully processed.
- the personal data has to be deleted due to a legal obligation..
If you wish to make a request for data deletion, then please contact us.
The right to restrict the processing of data
You have the right to restrict the processing of your data in certain circumstances. Restricting Cullens Driving School from processing your data means that we will continue to hold the data but will stop processing it.
Cullens Driving School will be required to restrict the processing of your personal data in the following circumstances:
- where you tell Cullens Driving School that the data it holds on you is not accurate. Where this is the case, we will stop processing the data until we have taken steps to ensure that the data is accurate.
- when the data has been processed unlawfully.
- Where Cullens Driving School no longer need to process the data but you need the data in relation to a legal claim.
If you wish to make a request for data restriction, then please contact us informing us what data you would like to be restricted.
Where data processing is restricted,Cullens Driving School will continue to hold the data but will not process it unless:
- you consent to the processing.
- processing is required in relation to a legal claim.
Where Cullens Driving School is to lift any restriction on processing, you will be informed in advance.
The right to data portability
You have the right to obtain the data that Cullens Driving School processes on you and use it for your own purposes. This means you have the right to receive the personal data that you have provided to Cullens Driving School in a structured machine-readable format and to transmit the data to a different data controller.
This right applies in the following circumstances:
- where you have provided the data to Cullens Driving School
- where the processing is carried out because you have given Cullens Driving School your consent to do so.
- where the processing is carried out in order to perform the services between you and Cullens Driving School
- where processing is carried out by automated means.
If you wish to exercise this right, please contact Cullens Driving School
Where a request for data portability is received, Cullens Driving School will respond without undue delay, and within one month at the latest. Where the request is complex or Cullens Driving School receives a number of requests, Cullens Driving School may extend the timescale for response from one month to three months. If this is the case, Cullens Driving School will write to you within one month of receipt of the request explaining the reason for the extension.
If the response to your request is that Cullens Driving School will take no action, you will be informed of the reasons for this and of your right to complain to the ICO.
The right to portability is different from the right to access. Although both involve a right to access your personal data, the personal data to be accessed is not the same. The right to access your data under the right to portability includes only personal data as described above. Access to data under the right of access includes all personal data relating to you, including that which has not been provided to Cullens Driving School by you.
The right to object to the inclusion of data
You have a right to object to the processing of your data in certain circumstances. This means that you have the right to requireCullens Driving School to stop processing your data. In relation to your services with Cullens Driving School, you may object to processing where it is carried out:
- in relation to the driving school’s legitimate interests
- for the performance of a task in the public interest
- in the exercise of official authority or
- for profiling purposes.
If you wish to object, you should do so by contacting us.
Where you object to processing,Cullens Driving School will stop the processing activity objected to unless:
Cullens Driving School can demonstrate compelling legitimate reasons for the processing which are believed to be more important than your rights
or the processing is required in relation to legal claims made by, or against, Cullens Driving School
If the response to your request is that Cullens Driving School will take no action, you will be informed of the reasons.
Rights in relation to automated decision making
You have the right not to have decisions made about you solely on the basis of automated decision-making processes where there is no human intervention, where such decisions will have a significant effect on you. However,Cullens Driving School does not make any decisions based on such processes.
If you wish to exercise this right, you should speak to Cullens Driving School
However, we may carry out automated decision making with no human intervention in the following circumstances:
- when it is needed for entering into or the carrying out of a contract with you
- when the process is permitted by law
- when you have given explicit consent.